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10 June 2021

Hon. Arlene Dunn
Minister, Aboriginal Affairs
Minister Responsible, Opportunities NB
Minister Responsible, Immigration
Minister Responsible, Economic Development and Small Business

Departmental Building, West Block
P. O. Box 6000
Fredericton, NB E3B 5H1

Via email:

Dear Minister Dunn:

Re: Changes to the Entrepreneurial Stream of the Provincial Nominee Program & Meeting Request

I am writing today regarding the New Brunswick Provincial Nominee Program (NBPNP), administered by the Department of Post-Secondary Education and Training and Labour (PETL) and Opportunities New Brunswick (ONB), and the changes that were implemented in January 2021. We met with a representative from ONB earlier this year to review the new program features, which our Immigration Advocacy Committee looked at more closely, gathering feedback from newcomers that came to New Brunswick under the former program.

On the positive side, the previous iteration of the program had more vague/unclear conditions that could be (and were) interpreted inconsistently. The new program addresses this concern because even though it has more (and in some cases more restrictive) conditions, they do provide clarity to applicants.

However, we remain concerned that there are many references to department officers having “sole discretion” and this is causing anxiety with the idea that regardless of the criteria met, the officer will be in charge of making the final decisions. Our organization has reached out on behalf of newcomers many times to get responses from government officials as in some cases the clients were not even provided a name of their “primary” contact person.

The committee is also supportive of reducing the pre-arrival time in the process as well as eliminating the required deposit, which has caused much friction between the Province and newcomers over the years. To compliment this reduction in time, we recommend that there is more communication with newcomers before they arrive – both with government officials, but also with the community. A mechanism to promote a virtual dialogue would be valuable to address this pre-arrival communication gap and reduce the learning curve for new arrivals to New Brunswick.

Our committee has provided the following feedback on aspects of the current policy that require further review by government:

  • Permanent residency status not being granted upon arrival is likely the most significant change to the regulations. While we appreciate the government is seeking to increase retention rates, it must be noted that this was a major differentiator between New Brunswick and the other provinces and a reason for newcomers to look at New Brunswick first. We are concerned with the need for provincial nominees to also interact with the federal government and the backlog in applications and steadily increasing processing times. Even if all conditions are met and applications are submitted in a timely manner, newcomers may still be victims of this backlog and bureaucratic indifference. For example, over the past year we have had newcomers in New Brunswick lose health coverage during a pandemic while waiting for a federal signature.

Exacerbating this situation is the provision that only allows one-time (three month) extension for Nomination Certificate.

  • Providing only a two-year work permit to “establish” a business and requiring that business to be “operational” for one year within this time frame is not reasonable. It is also unclear what “establish” or “operational” mean in context as no definition is provided.
  • Disallowing home-based businesses. The number of home-based businesses has been steadily increasing (excluding the pandemic) and not allowing newcomers with startup businesses to do so can be a further barrier to success. Our committee noted that the Canada Revenue Agency has long recognized home-based businesses as legitimate and has adjusted the policies as such.
  • Not allowing amendments to business plans it is unreasonable and demonstrates a lack of understanding of starting a business – problematic for the entrepreneurial stream of the program. It is a normal business practice to review and alter business plans on a regular basis – perhaps even monthly in the earlier stages of a business – even when an entrepreneurial is familiar with the community and the market in which they are operating. To expect a newcomer to stay with a business plan that was created pre-arrival is a recipe for failure.
  • The eligibility of export services is unclear from the guide and service expenses being disallowed from outside North America are provisions that would seem to negate one of the main advantages that newcomer entrepreneurs have to compete – their network outside of New Brunswick. Given that New Brunswick is the most export-dependent province in Canada, we should try to find ways to leverage our newcomers’ connections and diversify our exports – a stated goal of the Government of New Brunswick.

Overall, the committee suggests that there is misalignment between the province’s population growth ambitions and the changes made to the Provincial Nominee Program’s Business Stream. Newcomers that have reviewed the changes have come away with the message that New Brunswick is creating barriers that will act as disincentives to choose our province as their destination of choice. Retaining newcomers is a shared goal and it starts pre-arrival.

When overhauling a program like this, we suggest that consultation should be sought with the people and community that they will primarily effect. This would result in better policy that more reflects actual conditions “on the ground.” In the future, our organization or committee would be happy to provide feedback on proposed legislation or regulations in advance of it being adopted by government. We are also re-submitting our recommendation that the province create an “Immigration Ombud” position that can act as both an advocate for newcomers and a sounding board for policy makers. This has been included in our pre-budget briefs submitted to Minister Steeves in 2020-2021 and 2021-2022.

I am requesting to meet with you and senior staff to discuss these recent changes, our immigration efforts and how we can best work together to achieve New Brunswick’s population growth goals.


Krista Ross, CEO
Fredericton Chamber of Commerce

cc: Hon. Trevor Holder, Minister, Post-Secondary Education, Training and Labour
cc: Hon. Ernie Steeves, Minister, Finance
cc: Sadie Perron, CEO, Opportunities New Brunswick

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